Japan's Ministry of Finance has published an updated synthesized text of the 1976 income tax treaty with Romania as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). An updated summary of the application of the MLI has also been published.
The updates have been made considering Romania's deposit on 6 March 2023 of its notification confirming the completion of its internal procedures for the entry into effect of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) for 55 covered agreements (tax treaties), including the 1976 treaty with Japan.
As such, the MLI applies for the 1976 Japan-Romania treaty:
- in Japan:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2024; and
- with respect to all other taxes levied by Japan, for taxes levied with respect to taxable periods beginning on or after 5 October 2023;
- in Romania:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next taxable period that begins on or after 1 January 2024; and
- with respect to all other taxes levied by Romania, for taxes levied with respect to taxable periods beginning on or after 1 January 2024.
Click the following link for the Ministry of Finance's webpage on the BEPS MLI for more information.